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AI Summary
Review the current Twilio-based voice architecture to assess regulatory and civil liability exposure for the US and EU markets. Produce actionable legal sign-offs, contract amendments, and a voice-specific Acceptable Use Policy to transfer liability to end customers.
Legal Consultant - Voice/Telephony (USA)
Department: Legal
Employment Type: Temporary
Location: Remote - India
Description
About us:
Hiver is a modern, AI-driven customer service platform used by companies across healthcare, finance, logistics, education, and technology. We help teams deliver fast, human support across email, chat, phone, WhatsApp, and more — without the complexity of legacy helpdesks.
We’re a challenger brand in a category dominated by over-engineered tools. We build software that is simple, powerful, and genuinely helpful, and we operate internally with that same philosophy. If you want meaningful ownership, thoughtful teammates, and work that ships, Hiver is a great place to do it.
About the Project
We are a B2B SaaS company that has recently launched a Voice channel built on top of Twilio's APIs. We provision phone numbers from a shared pool and assign dedicated numbers to customers for inbound and outbound calling via our platform.
We need a specialist legal consultant to review our current architecture, assess our liability exposure, and produce actionable sign-offs and contract language — specifically for the US and EU markets.
This is not a generalist legal research project. We have already done the research. We need an expert who can read our existing brief, fill the gaps, and produce legally defensible outputs.
What you will do?
- Review our current Twilio account architecture (single direct account, shared number pool, no ISV/subaccount model)
- Assess where regulatory and civil liability sits today
- Recommend the contractual and architectural changes required to transfer liability from the platform to the end customer
- Benchmark against market standard (Aircall, Zendesk Talk, Freshcaller model)
- Voice-specific Acceptable Use Policy (AUP)
- ToS amendment / clickwrap gate for Voice feature activation
- Customer indemnification clause covering telecom-specific liability
- Immediate suspension clause (carrier spam block, TCPA violation, abuse signals)
- Recording consent allocation and logging requirements
- B2B-only use restriction for outbound voice
- Deepfake / AI voice cloning prohibition language
- Wiretapping / two-party consent state indemnification language
- India, Swiss FADP, and UK PECR regional carve-outs
- FCC KYC / KYUP rulemaking implications (April–May 2026 FNPRMs) — originating provider classification
- STIR/SHAKEN attestation obligations — does the platform need independent RMD registration or can it rely on Twilio's carrier status?
- TCPA compliance posture — number reassignment (RND/45-day aging), high-volume account scrutiny, B2C restriction
- Toll-Free Verification (TFV) liability allocation — platform vs end customer
- CPNI obligations — do they attach given the platform's VoIP provisioning posture?
- E911 / Registered Location requirements
- Interconnected VoIP provider classification — yes or no, and what it triggers
- 18 U.S.C. § 871 / Section 230 analysis — platform conduit defense
- ECS / Number-Based ICS classification under the EECC — does provisioning real PSTN numbers trigger per-member-state registration?
- EU AI Act readiness — emotion inference from voice (Article 5(1)(f) prohibition, Annex III high-risk classification, Article 50 transparency obligations); deadline August 2, 2026
- UK PECR / TPS / CTPS — AUP allocation and ICO exposure
- GDPR / ePrivacy Directive — call metadata retention, lawful basis, data controller/processor allocation
- Swiss FADP — sub-processor documentation, individual criminal liability shield for executives
- ISO 42001 audit readiness — LLM vendor agreements prohibiting training on audio transcripts
- HIPAA boundary — voice module restriction for BAA accounts vs downstream BAA chain with Twilio
- Accessibility obligations (ADA / EU EAA) — RTT/TTY on provisioned VoIP numbers
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